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HomeMy WebLinkAboutE-3 Staff Report - Measure W Funding Plan CONSENT ITEM E-3 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL VIA: SERGIO GONZALEZ, CITY MANAGER FROM: ROBERT DELGADILLO, P.E. DIRECTOR OF PUBLIC WORKS/CITY ENGINEER DATE: OCTOBER 5, 2020 SUBJECT: AUTHORIZE STAFF TO SUBMIT ANNUAL FUNDING PLAN FOR FY 2020/2021 TO LOS ANGELES COUNTY FLOOD CONTROL DISTRICT TO RECEIVE MEASURE W FUNDS THROUGH THE SAFE, CLEAN WATER PROGRAM BACKGROUND: The Measure W parcel tax ballot measure, also known as the Safe Clean Water (SCW) Program, was successfully passed on the November 6, 2018 election. Measure W revenues are generated through the collection of a special parcel tax based on the square footage of impervious surface on the taxed parcel. With the approval of the SCW program, the first annual parcel tax was collected in Fiscal Year 2019-20. The purpose of Measure W is to improve/protect water quality, capture storm water to increase safe potable water supplies, protect public health and marine life by reducing pollution, trash, and toxins/plastics from entering LA County waterways, and modernize the water system infrastructure. Of the total taxes collected, 40 percent will be returned to local municipalities for local projects and programs. In order to receive Measure W funds, each City is required to submit an annual funding plan as required by the transfer agreement with the Los Angeles County Flood Control District. RECOMMENDATION: Staff recommends the City Council take the following actions: 1)Authorize staff to submit Annual Funding Plan for FY 2020/20201 to Los Angeles County Flood Control District in order to receive Measure W funds through the Safe, Clean Water Program. APPROVED CITY COUNCIL 10/5/2020 Measure W Annual Funding Plan October 5, 2020 Page 2 ANALYSIS: On July 20, 2020, City Council authorized staff to execute a transfer agreement with the Los Angeles County Flood Control District (LACFCD). The LACFCD has provided the City of Azusa with the preliminary Measure W revenue estimates of $620,000, and in order to receive the Measure W funds, the City must submit an Annual Funding Plan to the LAC FCD on an annual basis. Once the Annual Funding Plan is submitted, staff will be allowed to draw down on the Measure W funds. FISCAL IMPACT: On November 6, 2018, Measure W (the SCW Program ballot measure) was successfully passed by the voters, and the Measure W revenues are generated through the collection of parcel tax. With the approval of the SCW Program, the first annual parcel tax was collected for Fiscal Year 2019-20. The City of Azusa will receive approximately $620,000 of revenues from the Measure W Safe, Clean Water Program once the Annual Funding Plan is submitted and accepted by the LACFCD. Prepared by: Reviewed and Approved: Robert Delgadillo, P.E., QSD Sergio Gonzalez Director of Public Works/City Engineer City Manager Attachment: 1)Measure W – Annual Funding Plan FY 2020/21 City of Azusa SCW Program Annual Plan 2020-2021: Budget Overview For the current Fiscal Year, the table below lists the expenditures, budgets for the expenditures, and the total budget for the City’s SCW Program Payment. Descriptions of the planned expenditures are included on the following pages. Total Budget - $620,000 Expenditure Type Expenditure Name Expenditure Budget Program 1 Citywide Catch Basin Cleaning $40,000 Program 2 Infrastructure Project Planning and Funding $50,000 Program 3 Stormwater and Urban Runoff Programs Planning, Funding, and Implementation $95,000 Program 4 Stormwater and Urban Runoff Monitoring and Reporting $170,000 Program 5 Water Quality Programs Administration and Coordination $50,000 Program 6 Membership fee for Regional Water Quality Planning by the GWMA $2,000 Program 7 Stakeholder and Community Outreach and Engagement $5,000 Project 1 Trash Capture Device Installation Project $100,000 Unassigned Projects Funding that can carry forward for future projects $108,000 Attachment 1 City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 2 of 13 Program 1: Citywide Catch Basin Cleaning Budget: $40,000 Description: This program consists of cleaning City catch basins to clear them of any debris and sediment that could potentially end up in local and regional waterways. Cleaning will be performed several times per year and is contracted through Los Angeles County Department of Public Works. Goal 1. Improve water quality and contribute to attainment of water-quality requirements The purpose of the State Water Board’s Statewide Trash Provisions is to improve water quality requirements for trash. This program will contribute toward compliance with Statewide Trash Provisions. Goal 2. Improve public health by preventing and cleaning up contaminated water The project will prevent water contamination by reducing the amount of trash that enters local waterways and the ocean. The program will improve recreational opportunities in accessible downstream waterways (e.g. the beach) by reducing the amount of trash and sediment that accumulates in those areas through storm drain discharges. Goal 3. Promote green jobs and career pathways The project requires a skilled workforce to ensure proper cleaning of the catch basins and record- keeping/reporting of the amount of debris/sediment collected. Quantitative targets and corresponding metrics Target 1. Annual volume of stormwater captured and treated. This target will be included when the Disctrict’s SCW Reporting Module—which is referenced in the Transfer Agreement as a tool to determine quantitative targets and metrics—becomes available. Target 2. Annual volume of stormwater captured and reused. Not Applicable Target 3. Annual volume of stormwater captured and recharged to a managed aquifer. Not Applicable Target 4. Annual creation, enhancement, or restoration of Community Investment Benefits. If none, discuss considerations explored and reasons to not include By capturing trash and sediment that would otherwise be conveyed through the storm drain system, the program provides multiple benefits including improved water quality and improved recreational opportunities in accessible downstream waterways (e.g. the beach) Target 5. Annual acreage increases in Nature-Based Solutions and claimed levels of NBS (with matrix demonstrating determination of good, better, or best, as outlined in Exhibit C). If none, discuss considerations explored and reasons to not include. Not applicable. Catch Basin Cleaning is needed to meet water quality requirements of the Statewide Trash Provisions. Target 6. Annual expenditures providing DAC Benefits. If none, discuss considerations explored and reasons to not include. This program is designed to meet the Track 2 water quality requirements of the Statewide Trash Provisions, which limits the ability to focus on the DAC-specific benefits. However it is worth noting that the project improves recreational opportunities to the general public in accessible downstream waterways. City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 3 of 13 Program 2: Infrastructure Projects Planning and Funding Budget: $50,000 Description: This program is to plan for, fund, and assist in the implementation of infrastructure projects identified in the WMP to meet water quality milestones. This includes City planning efforts to identify new projects, develop project concept and design plans, and submit project applications for grant and SCW Program funding. It also includes significant updates to the WMP that impact these planning efforts. Goal 1. Improve water quality and contribute to attainment of water-quality requirements WMP projects were developed to set forth a path to achieve water quality objectives in local waterbodies. Goal 2. Increase drought preparedness by capturing more stormwater and Urban Runoff to store, clean, reuse, and/or recharge groundwater basins. WMP projects prioritize the capture and reuse of stormwater, as it results in greater pollutant load reductions. Goal 3. Improve public health by preventing and cleaning up contaminated water, increasing access to open space, providing additional recreational opportunities, and helping communities mitigate and adapt to the effects of climate change through activities such as increasing shade and green space. The City prioritizes projects with multiple benefits such as those listed in Goal 3. Goal 4. Invest in infrastructure that provides multiple benefits The City prioritizes projects that seek to maximize multiple benefits. These potential benefits include, but are not limited to, water quality and water supply benefits, enhanced recreational opportunities, urban greening, and flood management. Goal 5. Prioritize Nature-Based Solutions The City prioritizes projects that seek to maximize multiple benefits, including Nature-based Solutions that enhance recreational opportunities and urban greening. Goal 6. Encourage innovation and adoption of new technologies and practices SCW projects prioritize innovative and new technologies that further the goals of the WMP and the SCW Programs, and improve the competitiveness of project funding applications. Goal 7. Provide DAC Benefits The City prioritizes projects that provide DAC benefits. These potential benefits include, but are not limited to, local water quality and water supply, urban greening, and flood management. Goal 8. Implement an iterative planning and evaluation process to ensure adaptive management WMP projects follow a formal adaptive management process to improve effectiveness. It is based on an array of metrics including progress toward water quality requirements, new water quality data, and recommendations from regulators and the public. Goal 9. Promote green jobs and career pathways The program requires a skilled workforce for its implementation and administration, which is comprehensive and far-reaching. City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 4 of 13 Program 2: Infrastructure Projects Planning and Funding (Continued) Quantitative targets and corresponding metrics Target 1-3. Annual volume of stormwater captured and 1) treated, 2) reused, 3) recharged. Project-specific targets will be included in individual SCW funding requests for those projects. Target 4. Annual creation, enhancement, or restoration of Community Investment Benefits. If none, discuss considerations explored and reasons to not include Project-specific targets will be included in individual SCW funding requests for those projects. Target 5. Annual acreage increases in Nature-Based Solutions and claimed levels of NBS (with matrix demonstrating determination of good, better, or best, as outlined in Exhibit C). If none, discuss considerations explored and reasons to not include. Project-specific targets will be included in individual SCW funding requests for those projects. Target 6. Annual expenditures providing DAC Benefits. If none, discuss considerations explored and reasons to not include. Project-specific targets will be included in individual SCW funding requests for those projects. City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 5 of 13 Program 3: Stormwater and Urban Runoff Programs Planning, Funding, and Implementation Budget: $95,000 Description: This program is to plan for, fund, and implement elements of MS4 NPDES Permit Parts VI.D.4- VI.D.10—the Stormwater Management Program Minimum Control Measures (MCMs)—as well as other programmatic (i.e. nonstructural) control measures identified in the City’s Watershed Management Program (WMP) to meet water quality milestones. The MCMs are split into subprograms for Progressive Enforcement, Public Information and Participation, Industrial/Commercial Facilities, Planning and Land Development, Construction, Public Agency Activities, and Illicit Connections and Illicit Discharge Elimination. Implementation of MS4 Permit Part III.A, Discharge Prohibitions, is related to Part VI.D.10 and as such is also included. The MCMs require the City to implement Best Management Practices (BMPs considered necessary by the Regional Water Quality Control Board (RWQCB) to reduce pollutants in stormwater to the Maximum Extent Practicable (MEP) and to effectively prohibit non-storm water discharges. This includes educating the public on stormwater pollution prevention, inspecting businesses and construction sites for proper BMP implementation, ensuring proper BMP implementation for applicable City activities, identifying and eliminating illicit discharges, enforcing regulatory noncompliance, and training staff in MCM implementation. This program excludes activities for which the City is implementing cost recovery through an existing fee. Also excluded are the MCM requirements for street sweeping and catch basin cleaning. Goal 1. Improve water quality and contribute to attainment of water-quality requirements This program requires implementing BMPs—most prescribed by the RWQCB—needed to reduce pollutants in stormwater to the MEP and to effectively prohibit non-storm water discharges. Goal 2. Increase drought preparedness by capturing more stormwater and Urban Runoff to store, clean, reuse, and/or recharge groundwater basins. This program increases water use efficiency and drought preparedness by prohibiting non-stormwater discharges. Goal 3. Improve public health by preventing and cleaning up contaminated water, increasing access to open space, providing additional recreational opportunities, and helping communities mitigate and adapt to the effects of climate change through activities such as increasing shade and green space. This program requires implementing BMPs—most prescribed by the RWQCB—to reduce pollutants in stormwater to the MEP and to effectively prohibit non-stormwater discharges. This improves public health by preventing and cleaning up contaminated stormwater. Goal 4. Implement an iterative planning an evaluation process to ensure adaptive management. This program is subject to modification through adaptive management of the Watershed Management Program, as well as by the RWQCB upon MS4 Permit renewal. In this latter process, the RWQCB considers in part comments provided by permittees. Goal 5. Promote green jobs and career pathways Implementation of this environmental program requires specialized training, and so promotes green jobs and career pathways. City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 6 of 13 Program 3: Stormwater and Urban Runoff Programs Planning, Funding, and Implementation (Cont.) Quantitative targets and corresponding metrics Target 1-3. Annual volume of stormwater captured and 1) treated, 2) reused, 3) recharged. Not Applicable Target 4. Annual creation, enhancement, or restoration of Community Investment Benefits. If none, discuss considerations explored and reasons to not include This program will improve local surface water quality and recreational opportunities in accessible downstream waterways and reduce pollution within the City’s communities. A metric for this target will be determined when the District’s SCW Reporting Module (referenced in the Transfer Agreement as a tool to determine quantitative targets and metrics) becomes available. Target 5. Annual acreage increases in Nature-Based Solutions and claimed levels of NBS (with matrix demonstrating determination of good, better, or best, as outlined in Exhibit C). If none, discuss considerations explored and reasons to not include. Generally not applicable. Most of the measures are dictated by the RWQCB and are institutional controls that do not require construction or structural modifications to the MS4. The exception is the Planning and Land Development Program; however this program is funded primarily through existing plan review fees and so is not included in the SCW program. Target 6. Annual expenditures providing DAC Benefits. If none, discuss considerations explored and reasons to not include. This program is designed to meet requirements of the MS4 Permit and WMP, which limits the ability to focus on DAC-specific benefits. However it is worth noting that program implementation will improve recreational opportunities to the general public in accessible downstream waterways, and will reduce pollution within the City’s communities. City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 7 of 13 Program 4: Stormwater and Urban Runoff Monitoring and Reporting Budget: $170,000 Description: This program is implemented to assess the City’s compliance with water quality requirements and to measure/improve the effectiveness of implementation of the Municipal NPDES, WMP, and SCW Programs. In terms of monitoring, this includes implementation of receiving water monitoring, outfall monitoring, and outfall screening under the Coordinated Integrated Monitoring Program. In terms of reporting, this includes the preparation of SCW Program Annual Plans and Expenditure Reports, NPDES Individual Annual Reports and Watershed Annual Reports, WMP Adaptive Management Reports, WMP Updates, TMDL Compliance Reports, and Reports of Waste Discharge. Goal 1. Improve water quality and contribute to attainment of water-quality requirements This program is implemented to evaluate water quality and the City’s progress toward attaining water quality requirements. The program is utilized to inform decision-making in the interest of improving water quality. Goal 2. Implement an iterative planning an evaluation process to ensure adaptive management. The program is iterative as monitoring and reporting is conducted (and required) on an established, regular basis, ensuring that implemented pollutant controls are routinely assessed, improved, and adaptively managed. Goal 3. Promote green jobs and career pathways The program requires a skilled workforce to conduct monitoring and compile, assess, and summarize water quality data. Quantitative targets and corresponding metrics Target 1-3. Annual volume of stormwater captured and 1) treated, 2) reused, 3) recharged. Not Applicable as this is a monitoring and reporting program. Target 4. Annual creation, enhancement, or restoration of Community Investment Benefits. If none, discuss considerations explored and reasons to not include Not Applicable as this is a monitoring and reporting program. Target 5. Annual acreage increases in Nature-Based Solutions and claimed levels of NBS (with matrix demonstrating determination of good, better, or best, as outlined in Exhibit C). If none, discuss considerations explored and reasons to not include. Not Applicable as this is a monitoring and reporting program. Target 6. Annual expenditures providing DAC Benefits. If none, discuss considerations explored and reasons to not include. Not Applicable as this is a monitoring and reporting program. City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 8 of 13 Program 5: Water Quality Programs Administration and Coordination Budget: $50,000 Description: This program is to administer the City’s surface water quality programs, including the Safe Clean Water (SCW) Program, Watershed Management Program (WMP), and the Municipal NPDES Program. Tasks include overseeing and assuring quality of planning, funding, and implementation activities, holding and participating in interagency program meetings, providing program summary reports and technical assistance, preparing comment letters, and engaging with program stakeholders and the community. Goal 1. Improve water quality and contribute to attainment of water-quality requirements This program is to administer the City’s SCW Program, which includes the achievement of SCW Program goals. This program includes administering the WMP and Municipal NPDES Program, which both support this particular goal. Goal 2. Increase drought preparedness by capturing more Stormwater and/or Urban Runoff to store, clean, reuse, and/or recharge groundwater basins. See response to Goal 1 Goal 3. Improve public health by preventing and cleaning up contaminated water, increasing access to open space, providing additional recreational opportunities, and helping communities mitigate and adapt to the effects of climate change through activities such as increasing shade and green space. This program is to, in part, administer the City’s SCW Program, which includes the achievement of SCW Program goals. Goal 4. Leverage other funding sources to maximize SCW Program Goals. See response to Goal 3. Goal 5. Invest in infrastructure that provides multiple benefits, prioritize Nature-Based solutions, encourage innovation and adoption of new technologies and practices, and invest in independent scientific research. See response to Goal 3. Goal 6. Implement an iterative planning and evaluation process to ensure adaptive management. This program is to administer the City’s SCW Program, which includes the achievement of SCW Program goals. This program includes administering the WMP, which supports this particular goal. Goal 7. Promote green jobs and career pathways. See response to Goal 1. Goal 8. Ensure ongoing operations and maintenance for projects. See response to Goal 1. Program 5: Water Quality Programs Administration and Coordination (Continued) Quantitative targets and corresponding metrics Project and program specific target will be included in individual SCW funding requests for those projects City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 9 of 13 Program 6: Membership fee for Regional Water Quality Planning by the GWMA Budget: $2,000 Description: The Gateway Watershed Management Authority (GWMA) is a regional water management group and an active member of the Greater LA County Integrated Regional Water Management (GLAC IRWM) committees for Leadership, Sub-region Steering, Disadvantaged Communities (DACs), and the DAC improvement program. GWMA membership facilitates the cooperative planning, resource development, and implementation of integrated, multi-benefit and regional water quality projects with neighboring jurisdictions who share the same watershed. Goal 1. Improve water quality and contribute to attainment of water-quality requirements The membership fee helps fund grant planning and applications for integrated, multi-benefit and regional water quality projects within the Gateway region. Membership in the GWMA also facilitates the cooperative planning, resource development, and implementation of these projects, which improve water quality and contribute to attainment of water-quality requirements. Goal 2. Increase drought preparedness by capturing more Stormwater and/or Urban Runoff to store, clean, reuse, and/or recharge groundwater basins. The water quality projects referenced in Goal 1 may include projects that capture stormwater and/or urban runoff to store, clean, reuse, and/or recharge groundwater basins. Goal 3. Improve public health by preventing and cleaning up contaminated water, increasing access to open space, providing additional recreational opportunities, and helping communities mitigate and adapt to the effects of climate change through activities such as increasing shade and green space. The water quality projects referenced in Goal 1 may include projects that improve public health by preventing and cleaning up contaminated water., increasing access to open space, providing additional recreational opportunities, and helping communities mitigate and adapt to the effects of climate change through activities such as increasing shade and green space. Goal 4. Leverage other funding sources to maximize SCW Program Goals. The membership fee leverages funding sources, as it helps fund grant planning and applications for projects that may be paid for in part with SCW Program funding. Goal 5. Invest in infrastructure that provides multiple benefits The water quality projects referenced in Goal 1 may include infrastructure projects that provide multiple benefits. Goal 6. Promote green jobs and career pathways. If funded, the water quality projects referenced in Goal 1 will promote green jobs and career pathways. City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 10 of 13 Program 6: Membership fee for Regional Water Quality Planning by the GWMA (Continued) Quantitative targets and corresponding metrics Target 1-3. Annual volume of stormwater captured and 1) treated, 2) reused, 3) recharged. Not Applicable as this is a monitoring and reporting program. Project specific targets will be included during project development. Target 4. Annual creation, enhancement, or restoration of Community Investment Benefits. If none, discuss considerations explored and reasons to not include Not Applicable as this is a monitoring and reporting program. Target 5. Annual acreage increases in Nature-Based Solutions and claimed levels of NBS (with matrix demonstrating determination of good, better, or best, as outlined in Exhibit C). If none, discuss considerations explored and reasons to not include. Not applicable as the impact of the membership fee on this target is indirect. Target 6. Annual expenditures providing DAC Benefits. If none, discuss considerations explored and reasons to not include. Not applicable as the impact of the membership fee on this target is indirect. It is worth noting that many Gateway IRWM Plan projects are located in a DAC or provided benefits to a DAC population, and that the GWMA is an active member of the GLAC IRWM committees for DACs and the DAC Involvement Program. City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 11 of 13 Program 7: Stakeholder and Community Outreach and Engagement Budget: $5,000 Description: This program will provide direct/indirect communication to educate the community and stakeholders on the importance of stormwater management and the Safe Clean Water (SCW) Program. Information will also be provided on City/Regional projects and how those projects are improving water quality and public health. This program will also provide businesses and residents with best practices to improve water quality. Goal 1. Improve water quality and contribute to attainment of water-quality requirements This program provides education needed to reduce pollutants in stormwater to the MEP and to effectively prohibit non-storm water discharges. Goal 2. Improve public health by preventing and cleaning up contaminated water, increasing access to open space, providing additional recreational opportunities, and helping communities mitigate and adapt to the effects of climate change through activities such as increasing shade and green space. This program will provide educational material to businesses and residents which will reduce contaminated runoff from conveying through stormwater systems which lead to local and regional waterways. Goal 3. Promote green jobs and career pathways. Provide information to residents on how they can obtain certifications and training to obtain green jobs and careers. Quantitative targets and corresponding metrics There are no targets related to this program as is Stakeholder and Community Outreach and Engagement. City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 12 of 13 Project 1: Trash Capture Device Installation Project Budget: $100,000 Description: This program consists of purchasing and installing trash capture devices in City catch basins to prevent debris from ending up in local and regional waterways. The devices that will be installed will be certified as full trash capture devices by the State Water Board. The devices will be installed in high priority land uses as defined by the Statewide Trash Provisions (industrial, commercial, high density residential, mixed use, and transportation). Goal 1. Improve water quality and contribute to attainment of water-quality requirements The purpose of the State Water Board’s Statewide Trash Provisions is to improve water quality requirements for trash. This program will contribute toward compliance with Statewide Trash Provisions. Goal 2. Improve public health by preventing and cleaning up contaminated water The project will prevent water contamination by reducing the amount of trash that enters local waterways and the ocean. The program will improve recreational opportunities in accessible downstream waterways (e.g. the beach) by reducing the amount of trash and sediment that accumulates in those areas through storm drain discharges. Goal 3. Invest in infrastructure that provides multiple benefits. By capturing trash that would otherwise be conveyed through the storm drain system, the project provides multiple benefits including improved water quality, improved recreational opportunities in accessible downstream waterways (e.g. the beach), and progress towards compliance with Statewide Trash Provisions. Goal 4. Promote green jobs and career pathways The project requires a skilled workforce to ensure proper procurement, installation, maintenance, and record- keeping/reporting of the trash-capture devices. City of Azusa SCW Program Annual Plan 2020-2021: Description of Programs Page 13 of 13 Project 1: Trash Capture Device Installation Project (Continued) Quantitative targets and corresponding metrics Target 1. Annual volume of stormwater captured and treated. This target will be included when the Disctrict’s SCW Reporting Module—which is referenced in the Transfer Agreement as a tool to determine quantitative targets and metrics—becomes available. Target 2. Annual volume of stormwater captured and reused. Not Applicable Target 3. Annual volume of stormwater captured and recharged to a managed aquifer. Not Applicable Target 4. Annual creation, enhancement, or restoration of Community Investment Benefits. If none, discuss considerations explored and reasons to not include By capturing trash and sediment that would otherwise be conveyed through the storm drain system, the program provides multiple benefits including improved water quality and improved recreational opportunities in accessible downstream waterways (e.g. the beach) Target 5. Annual acreage increases in Nature-Based Solutions and claimed levels of NBS (with matrix demonstrating determination of good, better, or best, as outlined in Exhibit C). If none, discuss considerations explored and reasons to not include. Not applicable. Full trash capture devices are needed to meet water quality requirements of the Statewide Trash Provisions. To meet this requirement with NBS would be cost prohibitive. Target 6. Annual expenditures providing DAC Benefits. If none, discuss considerations explored and reasons to not include. This program is designed to meet the Track 1 water quality requirements of the Statewide Trash Provisions, which limits the ability to focus on the DAC-specific benefits. However it is worth noting that the project improves recreational opportunities to the general public in accessible downstream waterways.